Hotels and Restaurants

Special Process

What is a Special Process?

A DBPR-licensed food service operator may use specialized food processing methods, like technologies or equipment typically seen at the commercial manufacturing level. For example, you may cure meat with the addition of nitrite (pink curing salt) on it, or you may use vacuum-packaging with an immersion cooker (Sous Vide), or you may have a molluscan shellfish tank. Written approval from DBPR is required BEFORE such operations can be carried out. A Special Process may require an approved HACCP plan, a Process Waiver, or both.

What is a HACCP plan?

A Hazard Analysis and Critical Control Points (HACCP) plan is a written document provided by the operator that describes the formal procedures for following HACCP principles. For general information on HACCP plans click here. HACCP Plan templates for the most common Special Processes can be found here.

What is a Process Waiver?

A written document issued by DBPR that authorizes a modification or waiver of one or more requirements of the Food Code.

The Special Processes listed below need a HACCP plan or Process Waiver (or both). These are examples and do not show all Special Processes requiring DBPR approval:

HACCP Required	Process Waiver Required	Special Process
✔		Reduced Oxygen Packaging (ROP) of Time/Temperature Control for Safety (TCS) foods limited to: Raw meat, raw poultry or raw vegetables Meat or poultry cured at a USDA regulated facility Food with a pH of 4.6 or less or a Aw of 0.91 or less Commercially manufactured hard cheese, semisoft cheese or pasteurized process cheese with no ingredients added on premises Fish that is frozen before packaging and remains frozen while packaged
✔		Reduced Oxygen Packaging – Sous Vide Note: A waiver will be required if the sous vide process deviates from the requirements of the Food Code, such as sous vide of fish or cooking sous vide products to temperatures different than the ones required on the Food Code.
✔		Reduced Oxygen Packaging – Cook-Chill Note: A waiver will be required if the cook-chill process deviates from the requirements of the Food Code, such as cook-chill of fish or cooking cook-chill products to temperatures different than the ones required on the Food Code.
✔	✔	Smoking food for preservation (not for flavor only)
✔	✔	Curing food (like corned beef, bacon, ham, etc) for preservation or by using curing salts (nitrites/nitrates)
✔	✔	Using food additives or components, such as vinegar, for food preservation or to render the food so it is not Time/Temperature Control for Safety (TCS) food (as with sushi rice)
✔	✔	Reduce Oxygen Packaging (ROP) of TCS foods not specified above Note: *ROP of fresh fish using 10K bags requires a waiver, but does not require a HACCP plan
✔	✔	Operating a molluscan shellfish tank for human consumption
✔	✔	Custom processing animals for personal use
✔	✔	Sprouting seeds or beans
✔	✔	Preparing food by another method that is determined by the regulatory authority to require a waiver (e.g. fermentation of TCS foods or dehydration of foods, such as beef jerky)

Note: A HACCP plan is not required if an establishment uses an ROP method for TCS food (other than fish) that is always labeled with production date and time, held refrigerated at 41°F or below, and removed from its package in the food establishment within 48 hours after packaging.

More info on HACCP and DBPR:

How do I get a HACCP plan?

Food service operators are responsible for writing their own HACCP plan. HACCP Plan templates for the most common Special Processes can be found here. You can also find guidance from the USDA here. HACCP training through an approved vendor can help operators ensure that their plan is complete, and there are businesses that can provide HACCP consultant services to write your plan for you.

What should a HACCP plan include?

A complete plan includes:

General information such as, name of the license applicant or license holder, license number, food establishment address, and contact information
A categorization of the types of TCS foods that are to be controlled under the HACCP plan
Flow diagram for each specific food or category type that identifies all ingredients, each step in the process, and Critical Control Points (CCPs)
Ingredients, recipes or formulations, materials, and equipment used in the preparation of each specific food or category type and methods and procedural control measures that address the food safety concerns involved
A critical control points summary for each specific food or category type that clearly identifies:
a. Each critical control point
b. The significant hazards for each critical control point
c. The critical limits for each critical control point
d. The method and frequency for monitoring and controlling each critical control point by the designated food employee or the person in charge
e. Corrective actions to be taken by the designated food employee or person in charge if the critical limits for each critical control point are not met
f. The method and frequency for the person in charge to routinely verify that the food employee is following standard operating procedures and monitoring critical control points
g. Records to be maintained by the person in charge to demonstrate that the HACCP plan is properly operated and managed
Training plan for food employees and supervisors that addresses the food safety issues of concern
Copies of blank records forms that are necessary to implement the plan
Additional scientific data or other information, as required by the regulatory authority, supporting the determination that food safety is not compromised by the proposal
If relevant, prerequisite programs: Supplier Agreement, Employee Illness, Personal Hygiene, Pest Control, SSOPs, etc.

Where do I submit my HACCP plan?

Submit your completed plan and any necessary documentation to DHR.SpecialProcess@myfloridalicense.com.

More info on Process Waivers and DBPR:

How do I get a Process Waiver?

Food service operators are responsible for requesting a Process Waiver for their Special Process before implementing.

What should a Process Waiver request include?

A complete request includes:

A statement of the proposed waiver of the Code requirement citing relevant Code section numbers
An explanation of how the potential public health hazards and/or nuisances addressed by the relevant Code sections will be alternatively prevented (supporting documentation may include a process review by a recognized process authority)
A HACCP plan if required (as specified under FC 8-201.13(A))

You may use this form: DBPR Special Process Waiver Request.

Where do I submit my Process Waiver request?

Submit your completed Process Waiver request and any necessary documentation to DHR.SpecialProcess@myfloridalicense.com.

Here are some of the most common Special Process situations and templates you can use:

Sushi Rice

Ingredients like vinegar can be added to sushi rice to render it non-TCS (i.e. with the intention of keeping it at room temperature without time or temperature control). If you use this Special Process, you must have an approved HACCP plan and Process Waiver.

NOTE: When sushi rice is held at room temperature under a proper Time as a Public Health Control procedure for no more than 4 hours, after which it is discarded, it is not a Special Process, and neither a Process Waiver nor a HACCP plan are required. For a copy of the Time as a Public Health Control procedure, click here.